The IPKat

Passionate about IP! Since June 2003 the IPKat has covered copyright, patent, trade mark, designs, info-tech, privacy and confidentiality issues from a mainly UK and European perspective. Read, post comments and participate!

How the EPO's sick leave policy stacks up internationally

In a post earlier this week on the continuing unrest at the
EPO, Merpel mused on whether the EPO’s proposals to reform sick leave and long
term invalidity policies were really so very different to the policies applying
in other intergovernmental bodies and IP offices in Europe. Here's what she wrote:

She wonders:
can some kind reader compile a comparative table of sickness-related provisions
and benefits that apply for each of the organisations mentioned above, and any
others she may have overlooked, so that she can publish it here and readers of
this weblog can see for themselves whether the EPO staff have a genuine
grievance or are merely in training for the Marathon Moan event at the next
Olympics?

Well, this cri de coeur came up trumps. A very kind
reader, who shall remain anonymous but who deserves enormous thanks nonetheless,
has prepared a detailed comparison of the sick leave policies of the EPO as
they currently stand and as proposed to be reformed (explained here),
set against those of the following bodies:

CERN

European
Commission

NATO

OECD

UN

WIPO

World Bank

Austrian
Civil Service

German Civil
Service

The
document, which Merpel has hosted here, goes far beyond what Merpel had hoped for. The author
cites sources carefully, explains the conclusions reached, and provides
measured analysis of how the EPO’s regime compares to the other organisations
listed. If any kind reader with knowledge of OHIM’s sick leave policy can add
to this table and/or provide a copy of the sick leave provisions, Merpel would be very interested to know
how it compares. She assumes it mirrors the EC provisions, but perhaps not.

Table 1: Main Findings

Organisation

Number of days of
uncertified sick leave in annual cycle

Maximum duration of
uncertified sick leave (working days)

Latest day of sick leave on
which a medical certification has to be issued

CERN

n/a

3

4

EC

12

3

4

EPO current

12

3

4

EPO proposed

3

3

1
– 4

NATO

6

2

3

OECD

9

3

2

UN

7

2

3

WIPO

7

3

4

World Bank

n/a

5

6

Austria, civil service

n/a

3

4

Germany, civil service

n/a

3

4

Merpel’s
most concise explanation of the main table of findings, reproduced above, will
follow an imaginary employee – let’s call him Benny -- who has the flu and is
absent from work for a few days as a result.

The middle column tells us that in most
organisations surveyed, Benny can only be absent from the office without a
doctor’s certificate for 2 or 3 days. In NATO and the UN, for instance, Benny
needs to have a doctor’s certificate if the absence lasts beyond two consecutive
days. At the EPO and European Commission, Benny needs to visit
a doctor and obtain a certificate if the absence lasts beyond three consecutive
days. So far, so good, and the EPO is in line with most of the other
organisations.

Assume Benny has returned
to work after three days’ absence. Six months later, he gets food poisoning and
is incapacitated for 24 hours, requiring him to take a day off work. In every
organisation surveyed, including under the EPO’s current regime, Benny could report
in sick, tell his boss he expected to be in tomorrow, and this would be
excused. Under the EPO’s new regime however (see column 1), Benny would already have completely
exhausted his entitlement to uncertified sick leave for the full year, and
would thus be absolutely required to visit the doctor that day and obtain a certificate to
prove he was ill. He would have to produce that certificate to the EPO on the same
day. (Merpel doesn't know how this works in Germany, Austria and the Netherlands, and has only the sketchiest understanding of human healthcare, but she sometimes has difficulty in getting a same day appointment with her vet. Presumably humans never have such problems.)

Benny would have to juggle these obligations with the requirement that he be at home between the hours of 10am
– 12 midday and 2 pm – 4 pm in case the EPO decided to send a doctor to the
house to check he was not malingering. He could leave the house, if he managed to get in touch with the President of the EPO and Mr Battistelli was agreeable to his absence from home.

For readers
who want to read more and to verify that the data is reliable for comparison purposes, Merpel can only
suggest they pore over the details provided by her anonymous source in the linked document.

Merpel's own
instinctive reaction is that the current allowance of 12 days uncertified leave in both the EPO and European Commission appears very generous, but this does not justify the level of bad faith and suspicion evident in the reformed system. What employee could feel that there can be a relationship of trust
with an employer who insists on a doctor’s certificate being provided on the
very first day of an illness and who also (uniquely among the organisations
surveyed) imposes an obligation to wait at home for the company doctor to ferret
out fraudulent claims of illness during both morning and afternoon on each and
every day when one is ill.

Finally, while the survey mentions the sick leave policies of the German and Austrian civil services, Merpel wonders if there are any readers willing to share how sick leave operates in each of the national IP offices which are under the stewardship of the delegates to the Administrative Council. These delegates had no hesitation in imposing the new sick leave regime on EPO employees at the request of the EPO President. Merpel wonders:

Did the AC delegates approve the EPO's new regime because similar provisions already apply in their own national IP offices?

If not, should readers expect their AC delegates to push through similar reforms on their home turf?

If the national regimes are more liberal, and the AC delegates don't intend to push through similar reforms at home, is there something in the Weissbier that causes one's views to harden while in Munich and to soften on the plane or train home?

Merpel thinks she knows the answers -- but she would love to be wrong.

As ever, Merpel welcomes comments, but
begs to remind readers of the following:

Henceforth, in respect of all EPO-related
blogposts, no comment will be posted if it is merely
ascribed to "Anonymous".
Any reader wishing to conceal his or her identity must adopt a pseudonym (which should
not be obscene and should not be the name, or the mis-spelling of the name, of
a real person). The pseudonym need not be an actual login name, as long
as it is stated clearly at the beginning and/or end of the comment itself. This
way, it will be easier for people who post later comments to identify and
remember the earlier comment-poster and to recall the discussion string.
Where, as has already happened on occasion, a string carries over from
one blogpost to a later one on the same or a related subject, readers will be
encouraged to use the same pseudonym for the sake of continuity.

How the EPO's sick leave policy stacks up internationally
Reviewed by Merpel
on
Thursday, April 30, 2015
Rating: 5

The IPKat licenses use of its blog posts under a Creative Commons Attribution-Non Commercial Licence.Share This:

54 comments:

The 12 days "free" sickness at the EPO has been abused by some staff, and that this should be curbed is not in debate. What has been introduced now is a deliberate punishing action for all staff. It would have been much better to target those who are abusing the system, but it seems more easy to apply drastic rules to everybody. This avoids line managers to take their responsibility. If a staff member is regularly absent on a Friday or on a Monday, then it is up to the line manager to discuss the matter with his staff member, not for everybody to be suspected.On the other hand, Dutch GPs are not likely to give a certificate, and this makes matters worse for staff in the Netherlands.The same can be said about invalidity. There have been abuses. Why were they not stopped in the bud? Here again it is easier to punish everybody. There was a regulation in place that the lump invalidity sum would be diminishing if invalidity was occurring between 55 and 60 years.What is done now is worse. Pinning down a colleague with terminal cancer at a place where he has no relatives is not fair. It will be even impossible to seek medical advice in the home country with the new system. Absence has to be authorised! This is not fair either, and plenty of staff would like to have at least a second opinion in their home country, be it only because they can have a better communication with doctors in their mother tongue. Why make things so complicated.On the other hand, forcing people with psychological problems to stay at home more or less the whole day, might not improve their status.When you are seeking a doctor's appointment, the latter does not care about the prescribed times of the EPO. What then?What is happening now is simply putting staff on general suspicion. It is not the first move in that respect from personal department, but now it has to gone far too much.Common sense should prevail, and as said cheats should be targeted, but not every staff under suspicion.

@ Merpel:"If the national regimes are more liberal, and the AC delegates don't intend to push through similar reforms at home, is there something in the Weissbier that causes one's views to harden while in Munich and to soften on the plane or train home?"

Some delegates do not understand the reforms.Some delgates do not care for EPO staff.Some delegates´ offices receive money for "projects" and would no longer get such money were they not to vote in favour of BB´s reforms.Some delegates do care, are reasonable and do understand. But sadly, those abstained but did not vote "against" the sickening sick-leave reform.

@ Old Man:"On the other hand, forcing people with psychological problems to stay at home more or less the whole day, might not improve their status."

Management does not "believe" in psychological diseases/disorders. I was told that "those with psychological illnesses only have to find a Psychologist or Doctor who says that they are sick and then they go off on the invalidity-scheme. And WE all pay for this!"

This was before the latest tragedy in the Englische Garten.But I am certain the same managers will say the same things now and still presume that anyone with a psychological problem is faking it.

It really is sickening.

On pointing out that the latest reforms are too harsh and unjustified one gets told that one should have trust in the management and that the rules - although they in principle allow for all sorts of unreasonable and draconian decisions - will apply such rules "reasonably" and "humanely".

I wonder why one does not simply MAKE them reasonable and humanely if the intention anyway is to apply them in that way?The only logical conclusion of having the possibility to apply them in a dictatorial and inhumane way is that one wants to have this possibility open should the management nevertheless decide to use those rules in a cruel and inhumane way.

•Did the AC delegates approve the EPO's new regime because similar provisions already apply in their own national IP offices?

It´s a stupid question. Of course, similar provisions don´t apply in their own country. A diplomat who get invalid in Saoudi Arabia doesn´t have to stay in that country until he will retire.Invalid expat staff are allowed to go back to their home country.This inhuman regulation is a Battistelli invention. Nowhere else around the world, you will find similar provisions,

•If not, should readers expect their AC delegates to push through similar reforms on their home turf?

The implemention of such regulation would be illegal in their home country. Only a criminal regime, where the rules of law don´t apply anymore, could implement such oppressive regulation.Invalid staff are not productive and cost money for the EPO.The purpose of this regulation is clearly to bring the invalid staff to suicide. Invalid people will be forced to remain far away from their home country, without their family support.They are also not allowed to go outside between the hours of 10am – 12 midday and 2 pm – 4 pm in case the EPO decided to send a doctor to their house, How could an invalid survive ?

I am afraid that this will only mean more suffering for those already affected by a condition. This bill is a total nigthmare

The costs of controlling cheaters is higher than the costs of cheating. This is an entire non-sense designed by PD 43 (Battistelli's right hand's spouse). Projection and frustration seems to be the recurrent specs of any bill passed by these people who hate EPO staff although they belong EPO staff.

The EPO is on a sick path, a very sick one, management wise. I predict that very soon a drama will happen at the EPO with a desperate colleague not only turning his/her anger and suffering against him/her, but against others.

@ hardworking renewal fee payerI think your comment is a an unwarranted, wanton slur on the vast majoritty of EPO staff (quite apart from the fact that in my view anyone praising him/herself as being "hardworking" is by that fact already rather suspect ...)

This obligation to be at your place of residence intrigues me. What about people who live alone? I guess a lot of EPO staff are single or have family back in their home countries? Even the President himself would fall into this category, I believe.

If someone in this group is bedridden (a simple tummy bug may suffice), surely they'd be better off in a place where friends/relatives can cook and care for them?

Staying alone and sick in an empty flat is simply irresponsible and not conducive to a speedy recovery.

Hang on. I'm missing something i this debate. What is preventing EPO staff moving away from the EPO back to their country of origin, and seeking treatment under that health care system? Let's say I fall ill while at the EPO, such that I can no longer perform my duties. I don't want to remain in Munich. I return home to London and seek NHS treatment there. What is preventing me from doing so?

"return home to London and seek NHS Treatment..."You can do it just like that, only, if you first quit working for the EPO. Otherwise you must seek permission from the EPO and they can refuse. Even terminally ill people must obtain a permission to move back home to die, or quit the EPO. The EPO decides now where you are going to die. Fine stuff.

not only do you have to quit working for the EPO, you also have to find an insurance company willing to cover your claims. Assuming you are around 50 years of age and seriously ill it seems rather unlikely to me that you find any health insurance at all. So the statement ". . . just go back . ." is absolute nonsens !

A bit of history is relevant here. The Service Regulations of many international organizations are or were originally similar with respect to sick leave. There were problems with unclarity of definitions and in particular what should happen when there was disagreement between the doctor of the sick person and the President's doctor. This led to allegations of abuse by both sides. About 9 years ago the then President proposed to change the regulations such that the opinion of the doctor appointed by the EPO would prevail and the person should return to work pending resolution of the dispute following consultation of a third arbitrating doctor agreed by both doctors. The Staff representatives wrote a Council document (in those days they still could) which was so persuasive that the EPO withdrew the proposal.

Instead a joint staff-management working group was set up to consider all aspects of health, including sick leave management, reintegration, verification, and prevention. The WG tried to resolve every problem mentioned by both sides.

The final result was a Health Policy for the EPO based on best practice in the literature, and other big organizations. The basic principles of handling sick staff were early contact with the manager and the (new) Occupational Health department, and assistance from the latter to reintegrate to work.

Only when there was no cooperation from the staff member could the formal verification procedure be invoked. Also here the WG produced a new, fair and medically consistent system, where the final decision was made by a three doctor committee: the staff members doctor, the EPO doctor, and a third taken from a panel with relevant specialities whose members were jointly agreed by the management and the staff representatives.

This new system worked well on the whole. There was a reduction in sick leave, and complaints about abuse declined also. The whole policy had a built -in 5 year review provision.

All the incoming President had to do was to invoke this review procedure and together with staff work out what needed tweaking. Instead he flouted it from the word go and has now ripped it up completely.

How can the President claim to be sincerely interested in "social dialogue" in these circumstances?

In summary, EPO staff are up in arms because they now have to provide proof that they are sick.

Those in the EPO who criticise this new regime are hypocrites. Why? Because the very same EPO staff ask professional representatives to provide a medical certificate if there is a need to postpone oral proceedings due to ill health. Worse still, some insensitive examiners have been known to ask professional representatives to file death certificates if postponement of oral proceedings is requested on the grounds of bereavement.

EPO staff, you cannot apply a harsh set of rules to professional representative for many years, and then expect our sympathy when similar rules are applied to you. If you still wonder why professional representatives are indifferent to your "plight", contemplate the words of the poem "First they came..." by Martin Niemoller.

What I don't get is why you have to stay at home. What happens if you suffer from treatable bipolar disorder, happen to be having a bad day and a walk or some running might help? Also what if you have a muscular/skeletal problem and the best remedy is exercise or, more importantly, if you need urgently to get medication or indeed (as you have pointed out) need to see the doctor so that you can be certified? This all seems terribly unfair and somewhat procrustean. Has any study been done on fraudulent leave in the EPO?

The working rule is that if you have excessive sick leave at the office then it is usually because there is something wrong with (or at) the office - perhaps that could go on sick leave too ... but how would it stay at home?

The rules on summons for oral proceedings are clear and public, a pity it doesn't work out for you.

Personally I am not indifferent to the current EPO problems and cannot understand why you quote a post-WWII poem in relation to EPO health care issues and call EPO staff hypocrites, it shows poor understanding of the matter at stake and a lack of respect towards the IP community in general.

Did the AC delegates approve the EPO's new regime because similar provisions already apply in their own national IP offices? No, BB is not there *

If not, should readers expect their AC delegates to push through similar reforms on their home turf? Yes, but BB did not ask*

If the national regimes are more liberal, and the AC delegates don't intend to push through similar reforms at home, is there something in the Weissbier that causes one's views to harden while in Munich and to soften on the plane or train home? Yes, too much alcohol*

*“We delegates at the AC are the great secret keepers, the ones who don't want you to think that anything is wrong.”

After 6 months away from this site because of the overemphasis on EPO employment relations at the expense of discussions on other matters, I pay a visit to find nothing has changed. Now we have another article attempted to demonstrate how tough life is for EPO employees by comparing a benefit with those received by other international organisations who run their own gravy trains.

You are welcome to your opinions of this blog and to express them here. However, you are not welcome to make up your own facts. The coverage of various matters at the EPO is in no way "at the expense" of other topics, which continue to be covered here as fully as they always have been.

What I don't get is why individuals who are not interested in the EPO still take time to read the posting and comment. Is it some form of masochism?Some postings do not particularly interest me and I just glance at them. But I read all the EPO ones. I don't work there, but what a saga!!

Tristan,The answer arises from a simple distrust from BB and PD4.3 (Head of HR) of staff. The have given themselves the right to hold staff at their p,ace of employment because they think staff could be faking invalidity or could recover sufficiently to do some work. Thus only they can give permission to staff (and their family) to move away for treatment or continued existence. In practice I don't doubt that I would be allowed to seek particular treatment elsewhere - but I would have to ask permission first and, presumably, justify my wish to their satisfaction. The fact that I would have to show 10 years of invalidity and be over 55 before I went is appalling. Even the ban on any other paid activity is, to say the least, disappointing. While I may become unable to hold down a job at the EPO, I could still, for example, be able to intermittently perform some work - Stephen Hawking would presumably be banned from everything he does at the whim of the EPO management and be forced to live near the EPO for 10 years.As I said, the practice may be less malign, but top mgt has given itself basic control of invalid staff. I cannot imagine having gone abroad on holiday, having had an accident in my hotel and finding myself forced to live there until I'm 55 and for at least 10 years because the hotel mgt thought I might make some recovery and they could save money. Would anyone?

First of all, you don't know who I am, what I am (I might be your boss or your client!) and how hard I might or might not be working, so keep your gratuitously offensive tongue in check, please.

Secondly, it seems to be quite clear why you have to be so hard-working: anyone who can't even quote a six-letter name correctly (I'm Fafnir, not "fafnit") will have to work much harder and longer hours than someone who gets things right first time round.

"In practice I don't doubt that I would be allowed to seek particular treatment elsewhere - but I would have to ask permission first and, presumably, justify my wish to their satisfaction."

That is the problem: You might not doubt that. However, some of the Eponians do have their doubts and for good reasons too.

Whenever management´s attention is drawn to the fact that the current rules could be used in an incredibly cruel and unjust way the answer one gets is that staff should trust the management not to apply the rules in an inhumane way.

Now, if the management´s intention anyway is to apply the rules in a humane way then why not making rules accordingly in the first place?

For me the only logic conclusion is that the management wants to have the possibility open to apply the rules harshly and not to take a "humane approach". It therefore seems likely that said rules will NOT be applied reasonably in all cases. In which cases they will be applied unreasonably is pretty much the choice of the top management and - given the current situation - it probably will hit the so-called "low producers".

Moreover, EPO staff has no possibility to challenge adverse decisions taken in HR matters such as those relating to sick leave or invalidity and therefore are entirely dependent on the goodwill of those who apply the new rules.

Katwoman,I agree with you about the doubt. The difficulty of mgt is their inability to see any policies other than by setting a set of rules. We are thus inundated with sets of roadmaps as they have to codify everything to make up for their lack of empathy and ability to discuss matters rationally.My comment above was meant to be a less confrontational approach which, nevertheless, highlighted the seriousness of the policy. If they don't intend to apply the option, why include it, as you, I, and many others would wonder? The balance has been swung to an immunity driven mgt dictatorship and the consequences are worrying. I just hope I and my family do not suffer any serious Ill-health as the additional burden may not be light.

@ Lone RangerNot only Board of Appeal members and thick people are under the fire of the EPO. The whole Patent Administration has a long history of mismanagement and the last production objectives made life a nightmare for many examiners having a bit of work dignity.All we see here the top of the iceberg.

Whenever management´s attention is drawn to the fact that the current rules could be used in an incredibly cruel and unjust way the answer one gets is that staff should trust the management not to apply the rules in an inhumane way.

Exactly. And if management happens to misjudge the situation, whether that be related to an old grudge they might bear against you or simply caused by incompetence, your only recourse is filing an appeal which will take 5+ years to be dealt with. In the meantime there is no possible of petitioning for injunctive relief.

Note that resigning is not a real option, or at least should not be one. The EPO is obliged, as an international organisation profiting from privileges and immunities, to provide its employees with social security. The current scheme is effectively an attempt by the EPO to deny its responsibilities.

There is no doubt that at least this 10-year house arrest rule would not stand up to serious scrutiny by a real court. But the question is when this rule will be scrutinised, if ever. The ILOAT will likely deny receivability of any appeals against the Council's decision, arguing that the decision still needs to be "individually implemented". In other words, we have to wait for the first actual case of inhumane treatment. And then the ILOAT likely will merely agree with the complainant that the Office should, in his case, allow him to return to his home country and that there is no need to look into the underlying rule.

The situation of examiners is so desperate that many older, experienced examiners will go on early retirement. As for the younger ones, there seem to be many job openings in the DE, GB, FR national offices who are interested in the expertise of EPO examiners. I also heard that people who had been offered a post as examiner have turned it down in view of the present situation. That will leave the EPO without experienced examiners. Those who remain will have to grant patents without any serious examination in order to achieve their target, which has been raised by 20 to 50% compared to last year. So effectively the applicants will be paying for something they do not get. That should worry some of them, I should think?

Well why do you not rearrange your favourites and clear your history, you seem to have been hooked on EPO matters and now it has been haunting you. In contrast the IP Kat blogs are rounded up every week and there are plenty enough other topics to enjoy. As regards EPO matters IPKat is keeping track of the various EPO roadmaps, this backed up with real facts, and EPO management seems to be not a little bit off track, I feel for the EPO staff and I hope the best for them.

Good to see all those fees I've paid over the years being able to support early retirement policies at the EPO. I shall carry on my hard work for many years to come to ensure such rights are protected.

That's right! That is why VP1 begged BB to stop/postpone the Pension reform bill, worse is to come…

We EPO staff have to face this offspring of Machiavelli, trapped in a historical rollercoaster that can bring us a monarchy-toppling French Revolution , then a few years later Napoleon Bonaparte as emperor and now King Louis XIV of France who rules on the principle ‘L’Etat c’est Moi’.

These days if I am asked what kind of organisation the EPO is, I say, nobody knows.

To the troll calling himself "hard working renewal fee payer":1) you should know very well that hard workers are everywhere, at EPO as well as among renewal fee payers. The current EPO policies are punishing all workers, including hard workers.2) Skiving? You said skiving? This shows you are either not informed on the issues at stake, or you pretend not to (president's troll?).3) Thanks for paying for our early retirement: soon you will have to find another reason for which you pretend to pay your renewal fees.4) I bet that you have applied as an examiner at EPO but have not even been invited for an interview. Which is understandable, as we test the psychological stability of the candidates.

To hard working renewal fee payer, my last comment on the issue:I wrote "troll" because of your provoking tone.What we earn is what we were offered for the job, and there is no salary threshold for having your human rights respected.Sorry to take time from your hard work, best regards.

obviously it is up to you to decide for yourself whether you find that some author here qualifies as a troll or not.

However, the wikipedia definition of an internet troll is:

“a person who sows discord on the Internet by starting arguments or upsetting people, by posting inflammatory, extraneous, or off-topic messages in an online community (such as a newsgroup, forum, chat room or blog), with the deliberate intent of provoking readers into an emotional response or of otherwise disrupting normal on-topic discussion.”

Here are some examples of posts from the hardworking renewal fee payer:

- “I am also a hard-working taxpayer. Unlike EPO staff, who are neither.”,

- “oh dear, the EPO staff comments get more pathetic by the day. And, starting from such a low point, that takes some doing”,

- “Good to see all those fees I've paid over the years being able to support early retirement policies at the EPO. I shall carry on my hard work for many years to come to ensure such rights are protected.”

-“Don't judge everyone by your own lazy standards.”

As I said: It is up to you to decide for yourself but personally I personally find those posts deliberately provoking, inflammatory and totally off-topic (as the topic is the sick-leave regulations at the EPO).

I therefore find the term "troll" for the author of such comments totally justified.

it is not quite clear whether your post is "correct" or not. After all, it only reflects your opinion.

Moreover, it is questionable whether with the erroneous definition of "troll" being (merely) "provoking tone" one can define every anti-establishment comment as being "troll". That would require that every anti-establishment view is provocative in tone which is not the case. One can be very "anti-establishment" but still polite. However, one can also be "anti-establishment" and make trollish comments.

Several recent comments in this thread have been deleted, as they add nothing constructive to the debate. The contention that EPO staff are lazy and/or only interested in feigning illness has been both made and rebutted. Further comments along these lines, or attacks against other commenters, will be deleted.

Somebody upthread kindly posted a definition of "troll" as someone who posts intending to sow discord. So there is a fine line between a poster who stimulates to heighten the debate, from one who stimulates, just to sow discord.

I think we can, on this blog, rely on those who run it to see clearly when the line is over-stepped. it is not so hard to see who is trying to concentrate the debate and who seeks to dilute it. The closer the bebate gets to the heart of the matter, the greater the number of people who are getting uncomfortable and want to disrupt it.

But apart from relying on the blog police, posters who want this blog to remain respected and useful should be strict with themselves. Follow the well-known rules. Do not rise to the bait. Do not feed the troll.

All comments must be moderated by a member of the IPKat team before they appear on the blog. Comments will not be allowed if the contravene the IPKat policy that readers' comments should not be obscene or defamatory; they should not consist of ad hominem attacks on members of the blog team or other comment-posters and they should make a constructive contribution to the discussion of the post on which they purport to comment.

It is also the IPKat policy that comments should not be made completely anonymously, and users should use a consistent name or pseudonym (which should not itself be defamatory or obscene, or that of another real person), either in the "identity" field, or at the beginning of the comment. Current practice is to, however, allow a limited number of comments that contravene this policy, provided that the comment has a high degree of relevance and the comment chain does not become too difficult to follow.